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From August 2, 2003 through October 6, 2003 a group of volunteers participated in a TCS compliance solution for providers workgroup using HIPAA ComplyAssistant, a HIPAA compliance management tool. From my participation is this group I learned that:
1. For the most part, the TCS technical solution had been passively out-sourced to application vendors and clearinghouses with little or no input form providers.
2. Providers did not actively manage TCS compliance, and those who did focused on the technical solution and not on integrating the technical solution into the day-to-day actions of the workforce
3. Most technical solutions provided by application vendors and clearinghouses were "all or none." Which did not allow providers to implement upgrades until all of their payers were ready. This was a huge problem when shifting from use of local codes to HCPCS codes.
4. Application vendors could not manage TCS compliance for their client sites, and they were a little hesitant providing TCS updates because their clients had not asked for them.
5. In order to be successful with TCS, providers must manage the relationship between application vendor, billing service/BA clearinghouse, and payer by transactions type.
6. Most providers do not know what needs to be done or whom should do it which generally leads to finger pointing.
I wrote a white paper on the findings of the test group. The transcripts from each of the work group's test sessions and the white paper are available from the ShareHIPAA group's File section. Here is how the appear in the Files Section directory:
tcsicepp-final.doc 60KB
Msg #107
Msg #107
tcsmoduletest1.doc 73 KB
Msg #107
Msg #107
tcsmoduletest2.doc 115 KB
Msg #107
Msg #107
tcsmoduletest3.doc 92 KB
Msg #107
Msg #107
To access these documents, go to the ShareHIPAA home page
http://health.groups.yahoo.com/group/ShareHIPAA and sign in with your Yahoo! ID and password. Then select "Files" from the left column. Files are listed in alphabetical order, but this is Yahoo!'s alphabetical order. Conventional naming files are listed first, with the "gooble-dee-gook" named files at the end. Since these are named in gooble-dee-gook, you will have to scroll way down the Files directory to find them.
Sense the completion of the TCS workgroup, advances have been made in HIPAA EDI interoperability at the point between provider BA clearinghouse and payer BA clearinghouse. But clearinghouses say they aren't receiving the data necessary from providers (and probably some payers) to fill in all the necessary data elements. And many providers and some payers are saying that they can't use the data coming from the clearinghouses.
I think, and I know I am in the minority, that as a health care industry we have failed to apply basic business principles to resolving the HIPAA EDI dilemma and have rushed to create a technical solution that falls short. I believe the first step in any compliance initiative is for an organization to define the business deliverables, the requirements of regulation. Once these are determined, there will be some things that will be resolved through a change in processes and procedures, and there will be some things that will need to be addressed by technology. Because we failed to determine the business deliverables of the HIPAA TCS Rule, the need to understand how data was collected and processed and where the gaps are in our "process" was not address. Also, we would have mandated that the technical solution provide greater flexibility (all trading partners and intermediaries will not be moving at the same pace and codes sets will constantly be changing, and all payers will not require the same thing in the situational fields). Except for a few, the approach to HIPAA EDI has been backwards, i.e., a static technical solution was developed "by consensus", and therefore is generic. The problem with providing a generic solution is that there is no Generic Memorial Health System, Generic Physician Practice, or Generic Health Plan, Inc.
If you are responsible for managing the TCS compliance plan, or your are trying to assist providers and payers in managing their TCS compliance plan, I strongly encourage you to go to www.complyassistant.com and sign up for an on-line live demonstration of the TCS module of HIPAA ComplyAssistant. You may not need a tool to automate the management of TCS compliance, but at least you will see a very logical and consistent approach developed by David A. Feinberg, C.D.P. that I know will be beneficial to you. You will have a greater chance at being successful if you know how to do something. The demonstration will SHOW you how to do it. So if you can't afford a management tool, take notes! You may also want to read the white papers (accessible from the left column on the site's pages) or view the audio/video recordings on TCS by selecting "Presentations" from the top horizontal menu bar.
I would welcome your comments on the approach. Anything that can be done to make it more effective, will help us all. Any delay in achieving HIPAA EDI places the availability and provision of health care treatment, products, and services at greater risk. There are many forces impinging on the availability and provision of health care, but low cost claim adjudication processing does not need to be one of them.
Sincerely,
Barbara McGowin, CPC
Executive Recruiting
HIT Recruiting
(843) 824-8537
mcgowins@...
Connecting Healthcare Organizations with People,
Products and Services to Achieve HIPAA Compliance.
Executive Recruiting
HIT Recruiting
(843) 824-8537
mcgowins@...
Connecting Healthcare Organizations with People,
Products and Services to Achieve HIPAA Compliance.
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